UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF ...

Case 0:10-cv-61942-MGC Document 5-4 Entered on FLSD Docket 10/14/2010 Page 2 of 10
tiffanyoesterreich.com, tiffanysbijoux.com, tiffanyschmuckat.com, tiffanyschmuckch.com,
tiffanyschmuckdeutschland.com, tiffanyschmuckonline.com, tiffanyschmuckonline.net,
tiffanysde.com, tiffanysschmuck.com, and tiffanyzuerich.com, are false, invalid, or privacy
protected, Plaintiff’s counsel requested that I attempt to locate any alternative physical address at
which Defendant Lin could be served. As detailed below, I have been unable to identify a valid
physical address for service of process on Defendant Lin.
4. I analyzed the physical address provided by Defendant Lin on the contact section
of the WHOIS record for the domain name bijoux-tiffany.com, “Talsperrenweg 72, Ennepetal,
351122, HK, CN,” and determined this address is not valid because Ennepetal is not a part of
Hong Kong, China. Furthermore, “351122” is not a valid postal code in Hong Kong. I also
attempted to contact Defendant Lin via telephone at +86.5242652238, the contact telephone
number Defendant Lin listed on the WHOIS registration for the website operating under the
domain name bijoux-tiffany.com, and determined this telephone number is not valid. I
determined this number is invalid because it is not a registered telephone number in China.
Specifically, this telephone number is an unregistered number and has not been issued for
anyone’s use. When I called this number, a voice informed me that it was not registered and was
invalid.
5. I analyzed the physical address provided by Defendant Lin on the contact section
of the WHOIS records for the domain names bijouxtiffanyco.com and tiffanyandcopascher.com,
“The Landmark Central, hangkong, HK, 10012, CN,” and determined this address is not valid.
Specifically, the Landmark is a commercial complex with a shopping mall and two office
buildings. Also, a valid address in Landmark must include a shop number or room number. A
representative from the management office of the building confirmed to me that there is no
record of any individual or business using the name “Toronto Sport,” the alias Defendant Lin
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